Select Committee on Environment, Food and Rural Affairs Minutes of Evidence


Memorandum submitted by the Soil Association (Z38)

SUMMARY

    (i)  The Voluntary Initiative (VI) is ineffective, and a pesticide tax is required. The introduction of the Single Farm Payment marks the end of decades of public subsidies to farmers designed to achieve more and cheaper food production. The implications for pesticide use and regulation of this major change in public policy have yet to be considered (paras 1, 3-5).

    (ii)  The regulatory framework for agricultural pesticides has been shaped by policies that prioritised maximising output and reducing the direct costs of production. Neither are now objectives of Government policy—public support is decoupled from production, and focussed on environmental objectives. In addition, the success of organic farming, both at a technical and commercial level, has demonstrated that dependency on pesticides in farming is not in fact essential (paras 7-11).

    (iii)  In a future characterised by shortages of fresh water, soil erosion and restrictions on CO2 emissions, sustainable systems like organic farming will be the only means of delivering a healthy diet for the world's population in the medium term (para 6, Annex paras 11-13).

    (iv)  The VI is a product of the old, maximise production era; it is of questionable relevance today. The new goals of agricultural policy are, first, to meet the needs of consumers (who, as the Food Standards Agency have made clear, do not want pesticide residues in their food). Second, agriculture should be sustainable; the application of complex chemicals designed to kill plants or insects is not sustainable. Against a background of change and uncertainty, the VI does nothing (and does not claim) to influence the future direction of agriculture, or meet the new agricultural policy objectives (paras 12,14).

    (v)  The VI has generated plans, led to inspection of sprayers, and some spray operators and farmers have attended training courses and workshops. Claims of actual impact on the amount of pesticides being applied, or their impact on the environment in general and farmland wildlife in particular, may be premature. If the VI has some value, it could easily be made a requirement of cross-compliance by Defra, thus ensuring what is likely to be a significantly higher adherence, at no additional expense to the taxpayer (paras 12,21).

    (vi)  The VI is suffers from an number of serious, inherent flaws: it does not address market distortions; it will never cover all pesticide use and will not to cover some farmers likely to be causing most damage; these farmers (free-riders) will benefit most from the VI; it will not (and does not try to) influence the overall direction of agriculture, nor the toxicity, nor even necessarily the amount of pesticides used. There is evidence from farm assurance schemes and other voluntary agricultural schemes that the VI may not work (paras 16-17, 19-21).

    (vii)  The VI does nothing to adjust the current market failure in pesticide regulation and taxation—consumers of organic food effectively subsidise the price of non-organic food. The external costs of non-organic farming, including the external costs of pesticides, are met by all consumers or taxpayers, or fall on society as a whole (para 15).

    (viii)  Unlike a tax, the VI is least likely to influence those who are keenest on cutting corners, and who are least concerned about the environment. As a non-financial instrument, the VI inevitably follows changes in agricultural practice which are driven by economic forces. These forces, influenced by farmers personal preferences and existing practice, determine the pattern of cropping, and to some extent the structure and management of farms. The VI may then have some impact on the use of pesticides (para 18).

    (ix)  A pesticides tax has the possibility, and more likely the probability, of: influencing the direction that UK farming takes in future; reducing the amount (and if banded, the toxicity) of pesticides used; and addressing market distortions. A tax should be introduced without further delay (paras 22-25).

INTRODUCTION

  1.  We welcome the Select Committee's investigation, coming as it does at the start of a new era for European agriculture. The introduction of the "Single Farm Payment" marks the end of decades of public subsidies to farmers designed to achieve more and cheaper food production, and the implications of this significant change in public policy for pesticide use and regulation have yet to be considered. We believe that this enquiry provides an excellent opportunity to start this process.

  2.  This evidence expands on the points made in our one-page summary. In addition, in an Annex we cover the role and work of the Soil Association (Annex, paragraphs 1-5), and our interest in pesticide use in non-organic farming (Annex, paragraphs 6-8). We also cover two issues frequently raised about organic farming when pesticides are discussed: is organic farming a realistic alternative to farming dependent on pesticides (Annex, paragraphs 9-13); and the role of pesticides in organic farming (Annex, paragraphs 14-16).

BACKGROUND

  3.  For many decades the regulatory framework for agricultural pesticides has been shaped by post-war policy considerations, which placed a high priority on maximising output and reducing the direct costs of production. The framework has also been influenced by prevailing beliefs within a large part of the agricultural establishment that pesticides had no harmful effects (either on human health or the environment) and that there is no practical alternative to their routine use. Against this background important questions about the environmental impact and the safety of pesticides have been ignored, because to have addressed them would have threatened the basic presumption that pesticide use was an essential element of food production.

  4.  In the last few years the situation has begun to change significantly. A substantial amount of evidence has become available on the part played by pesticide use in the dramatic declines of farmland wildlife, including some well-known song bird species. Evidence suggesting that occupational exposure to pesticides can have serious health consequences has already begun to build. Many scientists have expressed concern about the impact of pesticides (and untested cocktails of several pesticides acting in combination) on human health, in particular on vulnerable groups like babies, children and the elderly. In addition, the success of organic farming, both at a technical and commercial level, has demonstrated that high dependency on pesticides in food production systems is not in fact essential.

  5.  The (then Conservative) Government acknowledged the problems associated with pesticide use in the 1990 White Paper on the Environment (This Common Inheritance) and set out its commitment towards pesticide minimisation and the encouragement of less pesticide intensive means of control. The Government has since re-affirmed this policy commitment, formulating policy towards the minimisation of risks associated with pesticide use and adopting a number of initiatives aimed at further developing this policy and ensuring its effective implementation. The decoupling of agricultural subsidies from food production in the recent Common Agricultural Policy reforms now provides a major new opportunity to reconsider the way in which pesticides regulation is framed.

THE FUTURE

  6.  In a world where CO2 emissions have to be controlled, fertile soils are being lost at an alarming rate, and fresh water resources are scarce, sustainable systems like organic farming will be the only means of delivering a healthy diet for the world's population in the medium to long term. There are no longer valid public policy grounds for pesticide regulation to be conducted on the basis that safety and risk must be balanced by the need to ensure that farming reliant on pesticides remains competitive.

  7.  Increasing food production in the UK (or EU) is no longer a goal of public policy, and state support for agriculture has just been decoupled from production. In fact, state support is just beginning to be "re-coupled" to environmentally benign farming practises (of which organic is recognised as the best example, receiving £60 per hectare under the new Defra Entry Level Stewardship scheme, compared to £30 per hectare for non-organic farming). The "feed the world" argument has never been credible, and in the world we are entering, with the need to conserve soil and fresh water, and severely restrict CO2 emissions, only sustainable farming systems will be capable of providing food for the future.

  8.  All acknowledge that agriculture is entering a period of significant change, with the introduction of the Single Farm Payment, but there is disagreement about the new direction or directions that farming will take.

  9.  Many in the non-organic part of the industry suggest that farms will continue to get larger and cropping systems simpler. It is argued that this will be necessary to allow the growing of commodity crops to remain, or to become, financially viable, now that growing such crops attracts no additional subsidy. Such changes would be likely to at least maintain if not increase the use of pesticides, and certainly to increase the extent to which spray regimes are applied less discriminately, as farm management and labour are spread over more farms and larger areas of crops. In some areas, these developments are already well underway, and mirror developments in non-organic agriculture in countries like the United States and Canada.

  10.  On the other hand the Government, following the recommendations of the Curry Commission, wants the farming and food industries to become more responsive to the public and the market. In the case of pesticides this would suggest very significant reductions or an end to their use. Against this background of significant change and uncertainty about future direction, the VI does nothing to influence the future direction of agriculture.

DO PESTICIDES HAVE A ROLE?

  11.  The assumptions that frame pesticide regulation should now be reconsidered in the light of new UK agricultural policy and the recent reform of the Common Agricultural Policy. Such reassessment would require a detailed consideration of the impact of pesticides (and the farming systems they make possible) on farmland wildlife and the environment, in particular in terms of CO2 emissions, soil conservation, and the use and pollution of fresh water. In addition, the hitherto largely ignored issues of the impact of pesticides and pesticide residues on particularly vulnerable groups, of multiple routes of exposure and exposure to multiple residues, and to the impact on individuals likely to suffer more and or higher levels of exposure to pesticides and pesticide residues, including bystanders, should be given urgent attention by the Government and the regulators.

  12.  As the Voluntary Initiative was a product of the old, maximise production of cheap food era; it is of questionable relevance today. The new goals of agricultural policy are, first, to meet the needs of consumers, who, as the Food Standards Agency have made clear, do not want pesticide residues in their food. Second, agriculture is required to be "sustainable", and the application of complex chemicals designed to kill plants or insects is clearly not a sustainable practice. The Government should look again at their approach to pesticides, and should aim to reduce and eliminate their use through economic and regulatory instruments, and through the promotion of sustainable farming systems that do not use pesticides, or aim not to use them.

WEAKNESSES INHERENT IN THE VOLUNTARY INITIATIVE

  13.  The Voluntary Initiative (VI) has succeeded in raising awareness, generating some management plans, getting some farmers to inspect their sprayers, and in getting a proportion of spray operators and farmers to attend training courses and workshops. It may have reduced the amount of active ingredient being applied, although given the annual fluctuations in spray use, and variation in run-off, both significantly affected by weather conditions and other factors, it may be a little early for those involved to make claims about any actual impact the VI is having on the amount of pesticides being applied, or their impact on the environment in general and farmland wildlife in particular.

  14.  There are, however, four serious flaws inherent in the VI: (i) it does not address market distortions; (ii) it is unlikely to cover all pesticide use; (iii) it will fail to cover those farmers likely to be causing most damage; (iii) these farmers will, as free-riders, benefit most from the VI; (iv) it will not (and does not try to) influence either the overall direction of agriculture, nor the toxicity or necessarily even the amount pesticides used.

  15.  The VI does nothing to adjust the current market failure in pesticide regulation and taxation, which ensures that consumers of organic food effectively subsidise the price of non-organic food. This is because the external costs of non-organic farming, and in particular the external costs of pesticides, are met by either all consumers or all taxpayers, or fall on society as a whole. For example, the cost of removing pesticides from water falls on all those who pay water bills, even if they eat organic food, and also pay the cost of avoiding pesticides through their slightly higher food bills. The work of the Environment Agency on monitoring and enforcing the use of pesticides is met by taxpayers. The notional but severe costs of the loss of farmland wildlife and wild flowers fall on society as a whole. (There is already a levy on pesticide sales, equivalent to 1.5% of UK sales. The revenue from this levy supports the work of the Pesticide Safety Directorate and the residue monitoring carried out by the Pesticide Residue Committee, but none of the other costs associated with pesticide use are covered.)

  16.  A further strong specific weakness with the VI is that it is by definition most likely to be adopted by those farmers already following best practice, or those who have the greatest desire to do so. It is least likely to influence those who are least concerned about the impact of pesticides, keenest on cutting corners, and least concerned about any environmental impact of their activities.

  17.  This leaves the problem of free riders. Unless the VI achieves 100% coverage, there will be a proportion of farmers not incurring the additional costs associated with compliance to the VI, and as already stated, on the face of it these are likely to be farmers causing most environmental and other damage through their use of pesticides. A tax has the enormous advantage of impacting on all farmers who use agricultural chemicals, of impacting most on those who use most chemicals, of not requiring inspection schemes or other complex (and sometimes costly to the farmer) schemes to try and ensure compliance, and has the essential element of fairness embodied in the polluter pays principle.

  18.  As a non-financial instrument, the VI inevitably follows changes in agricultural practice, which are themselves driven by economic forces. Once those economic forces, with some influence from farmers' personal preferences and existing practice, have determined the pattern of cropping, and to some extent the structure and management of farms, then the VI may or may not have some impact on the use of pesticides. A pesticides tax, on the other hand, at least has the possibility, and more likely the probability, of influencing the direction that UK farming takes in future.

WILL A "VOLUNTARY" APPROACH TO PESTICIDES WORK?—EVIDENCE FROM OTHER AGRICULTURAL INITIATIVES

  19.  An approach based on voluntary codes of practice and training, rests on the assumption that farmers generally obey existing laws, and will voluntarily undertake to meet higher standards. There is some evidence to suggest that the assumption that laws are generally followed by farmers is wrong. The Little Red Tractor scheme, which mainly requires farmers to obey existing laws, in other words, requires them to do things they would be doing already if they were obeying the law, has been widely criticised (for example in the farming press) as imposing an unnecessary and unfair burden on farmers. Assured Food Standards, who run the Little Red Tractor scheme, have said that in 2000, 22% of farmers were not conforming with the legal requirement to keep medicine records. The introduction of inspection, where the keeping of these records was checked (as a requirement of membership of farm assurance schemes) had reduced the extent of non-compliance with the law, but in 2004 there was still almost one in 10 farmers who were not obeying the law. If a legal requirement, coupled with regular annual inspections to ensure compliance, still fails to get almost one in 10 farmers to obey the law, it is hard to see how a voluntary scheme will be effective.

  20.  There is evidence from another, longer-running "voluntary initiative" that the voluntary approach is unlikely to work over time. In 1999, the Government began developing a strategy to reduce the use of antibiotics and other similar drugs on farms, due to concerns about the spread of antibiotic-resistant bacteria from farm animals to people. The strategy is heavily reliant on a voluntary industry initiative, the Responsible Use of Medicines in Agriculture Alliance (RUMA). In 1999 the combined total use of antibiotic growth promoters and therapeutic antibiotics was 437 tonnes. By 2003 this has risen to 462 tonnes. During the same period the total weight of animals slaughtered for meat production fell from 5.756 million tonnes to 5.294 million tonnes, making non-organic farming less efficient in the use of antibiotics now than it was in 1999.

  21.  In any event, if it is thought to have some value, the provisions of the VI could easily be made a requirement of cross-compliance by Defra, thus ensuring what is likely to be a significantly higher adherence to the Initiative, at no additional expense to the taxpayer.

THE CASE FOR A PESTICIDES TAX

  22.  UK farming and food production should now be changing, to be focussed on consumer demand and sustainability. Consumers do not want pesticide residues in their food, and the use of farming based on pesticide use is not truly sustainable. The fact that non-organic farmers do not have to pay the full costs of pesticide use (costs falling on all consumers and taxpayers) distorts the market. That distortion disadvantages farmers who do not use pesticides and consumers who eat food produced without the use of pesticides.

  23.  Scientific evidence for the negative environmental impact of pesticides, and farming systems made possible by the use of pesticides, is clear. There is continuing scientific concern and growing scientific evidence of the harmful effects of pesticides on operators, farmers, bystanders, and all people as they pass through vulnerable stages of their lives (before and for the next few years after birth, and in old age). There may be some people who are particularly susceptible to the toxic effects of pesticides. At the very least, as well as their clear, negative environmental impacts, there are clearly risks to human health, and unknowns, associated with the use of pesticides.

  24.  None of these new policy objectives, nor the long-standing or newer concerns are addressed by the VI. The VI brings some new disadvantages, including having least impact on the least concerned or aware farmers (while adding costs to the more concerned and aware users of pesticides). A pesticide tax would be fairer to farmers, fairer to all consumers and taxpayers, and more effective in delivering the Government's objectives for UK farming. A tax should be introduced without further delay.

January 2005

Annex

THE SOIL ASSOCIATION AND ORGANIC FOOD AND FARMING

  1.  The Soil Association is the main organisation of the organic movement in the UK, and also the main Government-approved certifier for the UK organic sector, certifying 70% of the organic food sold in the UK. Our responsibility for organic farming and food is evident throughout the entire food chain, from consumers, retailers, processors and wholesalers, to producers, researchers and policy makers. Membership of the Soil Association charity (over 25,000) includes members from every link in the chain and we represent them all in working to develop the organic sector.

  2.  The objectives of organic farming are the sustainable management of soil and the natural production of healthy crops with high nutrient levels, to produce healthy livestock, and healthy food for humans. This is achieved through good soil management focussing on the maintenance of soil organic matter levels and soil biological activity.

  3.  We hope that over time all farming and food will switch to modern organic methods. This is currently the only system that could in future allow us to feed ourselves sustainably, without depleting non-renewable resources like soil, fresh water and carbon. Certified organic farming accounts for about 4% of UK farmland. The market for organic food is worth over £1 billion, and is growing at 10% per annum. UK organic farmland is supplying about 45% of this and the rest supplied by imports. The Government's target is for 70% of the organic market to be sourced from UK farmers by 2010. Local and direct organic sales (through farm shops, box schemes and farmers' markets, and to local schools, pubs and restaurants) are growing at 16% per annum. An increase in the area of organic farming is one of the Government's "quality of life" indicators. The Defra action plan for organic farming, adopted in 2002, and updated in 2004, supports the development of the sector.

  4.  In the EU, 13% of Austria's farmland is organic, with market growth running at 11%, and Germany's annual market for organic food is twice the UK's, at £2.1billion. The world-wide market for organic food is worth £15 billion; the US market (the largest in the world) has grown at between 17 and 22% in recent years, compared to just 2 to 3% growth in non-organic food, and is expected to be worth $32.3 billion by 2009.

  5.  Defra, English Nature, the Royal Society for the Protection of Birds and others have published peer-reviewed papers setting out in detail the sustainability and biodiversity benefits of organic farming. The Food Standards Agency have said that consumers wishing to avoid pesticide residues in food or to buy sustainable food can buy organic, and English Nature wants to see more organic farming because there is more wildlife on organic farms. The Government accepts the sustainability, biodiversity and animal welfare benefits of organic farming, and the Government's policy on sustainable public procurement includes encouraging the purchase of organic food for those reasons. There is good evidence that organic farming conserves rather than depletes soils (as is the case with some non-organic farming).

THE SOIL ASSOCIATION AND THE USE OF PESTICIDES IN NON-ORGANIC FARMING

  6.  The Soil Association is interested in pesticide use for two reasons. First, we exist to promote sustainable agriculture, and we believe pesticide use encourages unsustainable systems of farming, which damage the environment, deplete wildlife and pollute the soil, fresh water and the atmosphere. Second, the way in which the indirect economic costs of pesticide use are apportioned between the farmers who use them and society as a whole, affects the cost of producing non-organic food, and thus the price differential between organic and non-organic food in the market place. The organic movement thus has a clear economic interest in the effective regulation of pesticides.

  7.  The evidence that agricultural systems that use pesticides damage the environment is now overwhelming, and we will not rehearse it further here.

  8.  We have a clear, and we think reasonable interest in trying to ensure that non-organic food is produced at a cost which fully reflects the direct and indirect costs of production. For example, the fact that all consumers, including people buying mainly or wholly organic food, pay through their water bills to remove pesticides from drinking water, means that organic consumers are effectively subsidising consumers of non-organic food. Organic consumers not only pay more for their own food, but also through their water bills allow non-organic consumers to buy their food at a lower cost. The Environment Agency estimates the cost of cleaning up pesticides to be around £120 million per annum. The Soil Association therefore favours non-organic agriculture paying the full indirect costs that the use of artificial fertilisers, pesticides and intensive livestock production impose on society.

WHY LISTEN TO ADVOCATES OF A FRINGE ACTIVITY LIKE ORGANIC FARMING?

  9.  A common response to suggestions that organic farming provides a viable alternative to non-organic is the suggestion that widespread adoption of organic farming techniques will lead to a range of dire consequences which make this alternative both unrealistic and undesirable, despite the clear environmental benefits. It used to be regularly suggested that widespread adoption of organic farming would lead to uncontrollable outbreaks of crop pests and diseases, and ill health and suffering amongst farm animals. Extensive and long-term experience of modern organic farming in a number of countries has made it clear that such claims are absurd.

  10.  It is also occasionally suggested that eating organic food poses additional dangers to human health compared to non-organic, because of the absence of chemical treatments, for example to control mycotoxins in grain. The Food Standards Agency has said clearly that there is no evidence to suggest that organic food is more dangerous or less healthy than non-organic food. Indeed recent research shows that mycotoxin contamination of organic food is either less, or of a sort that is less damaging to human health, than is the case with non-organic food.

  11.  The final reason given for suggesting that organic is not a viable alternative is the suggestion that widespread adoption of modern organic farming will lead to hunger and starvation, or at least an inability to feed a growing world population. Serious data is lacking, but such projections tend to assume that a rapidly growing world population will all need to be fed to the (unhealthy) standard of a well-off American. Such a diet involves the majority of agricultural production being used to produce animal feed for beef, chickens and pigs, to allow large-scale consumption of meat. These projections also ignore the current highly artificial balance of agricultural production, with high levels of subsidy encouraging over-production in North America and the European Union, and making the production of many export crops difficult or impossible in developing countries. It is sometimes suggested that agricultural production in North America and the EU would fall by 30% if there were a free market and free trade in agricultural products. Both the US and the EU have used publicly funded mechanisms to take agricultural land out of production in recent years.

  12.  Organic yields are sometimes lower than non-organic yields. The difference can be significant, around 20-30%, in the EU, where non-organic agriculture uses high levels of artificial fertiliser. In the USA, where fertiliser use is lower, a 20-year trial has shown comparable yields for maize (corn) with organic actually out-yielding non-organic in a drought year, because of the greater moisture retention in organically farmed soils. In developing countries, particularly for poorest farmers where regular access to artificial fertiliser and pesticides is problematic or even impossible, organic farming has increased yields significantly compared to the previous non-organic systems, sometimes by as much as 100%.

  13.  From this brief overview, it will be clear that whether organic or non-organic farming has a better chance of "feeding the world" is certainly not clear cut. It is probably true that if everyone on the planet were to try to eat a typical North American diet, organic farming would not be able to deliver. However, trying to produce meat on such a scale would cause horrendous environmental problems and spread serious diet-related disease beyond the current centres of the "epidemic" in the US and Western Europe. If the whole, and growing, population of the planet aspire to a healthy and balanced diet, with less meat and more pulses, rice and pasta, organic farming probably could deliver. What is clear is that in a world where CO2 emissions have to be controlled, soil conserved, and fresh water resources are scarce, only sustainable farming systems, like organic, will be able to deliver a healthy diet for the world's population.

ORGANIC FARMING'S USE OF PESTICIDES

  14.  If organic farming is not dismissed as irrelevant to a serious discussion about the future of farming and food because it will cause either ill health or famine, it is, somewhat paradoxically, dismissed as irrelevant because it also uses pesticides. Organic principles promote a holistic and sustainable approach to farming where additional pest control measures are rarely needed. Organic farming systems rely on prevention rather than cure, and the main forms of pest control are through cultural and management methods. Any external or synthetic input that is required to control disease and pests is a symptom of unsustainability.

  15.  The Soil Association is committed to working towards phasing out the use of all of the chemicals currently allowed under our standards, to sensible and achievable deadlines. We allow four pesticides to be used in organic farming: copper, derris, sulphur and soft soap. These are used to control insects and prevent diseases in crops; no herbicides (weed killers) are permitted. Almost all organic arable farming in the UK already has no need of, and no possibility of using, pesticides. Only small quantities of the four permitted pesticides are used, and then only as a last resort. For copper and derris, prior approval of use has to be given by Soil Association Certification Ltd. This is only granted if use is clearly justified and no alternative method of pest control is available. These four pesticides do not leave significant residues in food.

  16.  The principal use of the main chemicals used (sulphur and copper) is to protect potatoes and top fruit from fungal disease. Sulphur accounts for almost all of the pesticide used in organic farming—around 100 out of the 120 tonnes of pesticides used on Soil Association certified farms in 2003. Sulphur is also used in very large quantities as a pesticide and also as a fertiliser in non-organic farming. If use as a fertiliser is included, over 120,000 tonnes a year of sulphur is applied to UK farmland, less than 0.1% by organic farmers. By contrast, derris (16 applications in 2003, affecting around 202 hectares) and copper (86 applications affecting 879 hectares) are little used by organic farmers. The seven tonnes of copper currently used by organic farmers each year (likely to be around six tonnes in 2005 due to further restrictions on use) compares to 703 tonnes in non-organic farming, where copper is used as a pesticide, soil conditioner, disinfectant and growth promoter. Finally, UK organic farmers use around 17,000 litres of soft soap (which is photosensitive, and breaks down quickly in the environment) each year, mainly on protected crops.

January 2005





 
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